Launch of the Transfer Pricing Work Programme


Remarks by Angel Gurría

OECD Secretary-General

Brasília, Brazil - Tuesday 28 February 2018

(As prepared for delivery)



Dear Minister Meirelles, Secretary Rachid, CNI President Braga de Andrade, Ambassador Rangarajan, Ladies and Gentlemen,

It is my great pleasure to be here to launch the joint work programme with Brazil on transfer pricing, one of the core aspects of international tax policy. We are pleased to partner with the Federal Revenue Service of Brazil (Receita Federal) on this great endeavour, and in particular I would like to thank Secretary Rachid for his strong support. Let me also thank Mr. Braga de Andrade, President of Brazil’s National Confederation of Industry (CNI) for hosting us today, and Ambassador Rangarajan for the UK government’s generous financial support for this joint initiative.


In a globalised economy, in an inter-dependent world, multilateral co-operation is vital as a means of developing and promoting better policies for better lives for all people.
Cross-border challenges like digitalisation, taxation, migration, inequality, and tackling corruption and climate change require global solutions.


International co-ordination is nowhere more needed than in the area of tax policy. Cross-border intragroup transactions are a significant part of global trade. As a result, ensuring that the applicable tax rules are effective is very high on the international tax agenda. For governments, transfer pricing is about ensuring that taxable profits are not artificially shifted away. For taxpayers, it is essential to limit the risks of double taxation that may arise.


The OECD has been at the forefront of promoting multilateral partnerships to develop common approaches to tackle transfer pricing issues. The OECD Transfer Pricing Guidelines – which were just updated last year to incorporate the results of our work to counter Base Erosion and Profit Shifting (BEPS) – are followed by many countries around the world. They reflect a common understanding of how to apply the arm’s length principle, which is embedded in both the OECD Model Tax Convention and the UN Model Tax Convention.


As a G20 member, Brazil has been a key player in the main areas of the OECD work on tax over the last decade. Brazil is a member of the , and the Inclusive Framework on BEPS. Moreover, Brazil plays leadership roles in both of these fora, demonstrating its own deep commitment for multilateral solutions.


Yet, there are some important differences between transfer pricing rules applied by Brazil and the OECD Transfer Pricing Guidelines which need to be analysed for us to understand better how these differences play out for preventing double taxation and also profit shifting practices. Within the framework of the potential accession of Brazil to the OECD, transfer pricing is one of the key areas where alignment with the OECD’s internationally accepted standard is necessary. This constitutes a core principle and a benchmark that needs to be met by any new Member wishing to join the OECD.


It is in this context and with the aim to advance the conversation with Brazil’s Receita Federal on transfer pricing matters that we are launching, jointly with Brazil, this new project on “Transfer Pricing in Brazil”. In three phases over the coming year this project will analyse Brazil’s existing transfer pricing legal and administrative framework and its implementation; assess the strengths and weaknesses of that framework; and explore options for closer alignment between Brazil and OECD Members.


Ladies and Gentlemen,

Today’s seminar offers the opportunity to hear from a wide range of stakeholders on the challenges and benefits of the current system. Participants should take this opportunity to share their practical experiences and views on how to best protect tax revenues, while at the same time improve the ease of doing business and create a more attractive tax environment for foreign direct investment in Brazil.


This morning, I had the honour to launch with Minister Meirelles the Economic Survey for Brazil. One of the striking conclusions of the Survey is the fact that Brazil’s economy is relatively closed and poorly integrated into the global economy. There are also indications that exposure to trade is low, export performance has declined and there is also evidence that Brazil’s integration in global value chains is minimal. This is very surprising given the potential that participation in global value chains presents to the further development of your economy. Let us work together to explore the reasons for this and to what extent your current transfer pricing rules may play a role.


I am confident that our joint programme will be successful because it builds on the excellent co-operation that we have already established with Brazil on tax and other matters. I am confident that this will be another important step forward in deepening the relationship between Brazil and the OECD. Thank you.



See also:

OECD work with Brazil

OECD work on tax


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